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3 NIH Policy on Inclusion of Women & Minorities in Clinical Research Why does NIH have this policy? –Mandated by Congress, 1993 PL –Ethical principal of justice and importance of balancing research burdens and benefits

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4 Public Law PL Women and Minorities must be included in all clinical research studies Women and Minorities must be included in Phase III clinical trials & the trial must be designed to permit valid analysis Cost is NOT allowed as an acceptable reason for exclusion NIH to support outreach efforts to recruit and retain women, minorities, and their subpopulations in clinical studies

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5 NIH Policy on Inclusion NIH Policy and Guidelines on the Inclusion of Women and Minorities as Subjects in Clinical Research – Amended October, women_min/guidelines_amended_10 _2001.htmhttp://grants.nih.gov/grants/funding/ women_min/guidelines_amended_10 _2001.htm

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6 Updates to Inclusion Policy NIH Definition of Clinical Research New OMB Standards for Data on Ethnicity and Race Further Clarification about NIH- Defined Phase III Clinical Trials

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7 NIH Definition of Clinical Research (1) Patient-oriented research. Research conducted with human subjects (or on material of human origin such as tissues, specimens and cognitive phenomena) for which an investigator (or colleague) directly interacts with human subjects. Excluded from this definition are in vitro studies that utilize human tissues that cannot be linked to a living individual. Patient-oriented research includes: (a) mechanisms of human disease, (b) therapeutic interventions, (c) clinical trials, and (d) development of new technologies;

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17 OMB Directive Where can you find examples of data collection instruments that use the new OMB standards? –Many examples exist including: PHS 398 Personal Data Form questions 2000 US Census questions –Do not use the 5/01 Inclusion Enrollment Table or Target Table to collect data from subjects

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19 Additional Guidance on New Tables New Application or Competing Continuation Involving Collection of New/Additional Data –Must use new 5/01 Table

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20 Additional Guidance on New Tables New Application or Competing Continuation with No Plans to Collect New/Additional Data –May use Either: New 5/01 Table 4/98 Version of the Inclusion Table –Use form appropriate for your data

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21 Additional Guidance on New Tables Non-Competing Applications (Progress Reports) for grants that began before FY 2002 –May use Either: New 5/01 Table 4/98 Version of the Inclusion Table –Use form appropriate for your data

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24 Update to NIH Inclusion Policy NIH-Defined Phase III Clinical Trials –Evidence must be reviewed to show whether clinically important sex/gender and race/ethnicity differences in intervention effect are expected –Plans for valid analysis must be included in the design –Results of analyses must be reported to NIH

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25 Requirements for NIH-Defined Phase III Clinical Trials Research plan must include one of the following: –Prior studies support significant differences between subgroups: –Need plans to conduct valid analyses to detect significant differences between sex/gender and/or racial/ethnic subgroups For the purpose of this policy, Significant Difference is defined as a difference that is of clinical or public health importance based on substantial scientific data. This is not the same as “statistically significant difference.”

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27 Requirements for NIH- Defined Phase III Clinical Trial Applications OR: –Prior studies neither support nor negate significant differences in intervention effect between subgroups: –Plans to conduct valid analyses of the intervention effect in sex/gender and/or racial/ethnic subgroups (Does not require high statistical power) For the purpose of this policy, Valid Analysis means an unbiased assessment that does not require high statistical power and should be conducted for both large and small studies.

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32 Monitoring Compliance with the NIH Inclusion Policy Annual Comprehensive Report: Monitoring Adherence to the NIH Policy on the Inclusion of Women and Minorities as Subjects in Clinical Research html